In public comments submitted to the Centers for Medicare and Medicaid Services (CMS), HIMSS called for CMS to ensure that clinical quality measure sets for specialists include the same measures across different CMS programs.

The recommendation stemmed from a CMS proposal for a new Ambulatory Specialties Care model.

The Ambulatory Specialties Model utilized different quality measures than the Cardiology quality measures for the Medicare Shared Savings Program (MSSP) and the Quality Payment Program’s Merit Based Incentive Payment System (MIPS) for CMS. This presents cardiology specialists and developers with challenges ensuring that the correct measures are supported for all programs, creating additional cost and burden.

The recommendations, which were part of HIMSS response to the 2026 CMS Physician Fee Schedule Proposed Rule, are geared to support CMS and providers as CMS transitions quality reporting programs to FHIR-enabled digital quality measurement reporting.

HIMSS continues to call upon CMS to release a pathway and timeline for the adoption of digital quality measures for CMS programs, including a final determination on how the USCDI+ Quality Domain and HL-7 QiCore profile with its implementation guides (IGs) will need to be harmonized to support the nuance of capturing detailed clinical data to generate accurate and actionable measurement.

HIMSS has convened a Digital Measures Adoption Working Group to develop granular recommendations to support CMS adoption of FHIR-enabled digital measures. For more information, please contact Jonathan French, Senior Director of Public Policy and Content Development, at jonathan.french@himss.org.

HIMSS also opposed the removal of Social Determinants of Health (SDOH) data collection measures without being replaced by more actionable measures from the MIPS and MSSP programs. HIMSS noted that health systems mostly engrained the collection of SDOH data in their daily workflows as best practice while developers have already sunk costs into adding functionality that supports the data collection and reporting. Instead, HIMSS recommended that CMS replace the measures with the Addressing Health Related Social Needs Electronic Clinical Quality Measure, which requires a provider to refer a patient to community services when the data collection indicates the patient has a health related social need.